In a letter to Treasury and the IRS, the AICPA seeks changes to tax reporting requirements for partnerships and S corporations. In Soroban Capital Partners, the Tax Court analyzed the roles, ...

On occasion, taxpayers holding investments in foreign financial assets or with foreign financial institutions may find themselves in the uncomfortable position of realizing that they have failed to ...

Planning with revocable trusts has become increasingly popular in recent years. In many instances, the motives for using a revocable trust are nontax and include avoiding probate, asset protection ...

Taxpayers may be subject to the risk that an IRS examination could increase (or create) a gift tax or estate tax liability many years after a gift is made. Practitioners can help clients limit this ...

An advance of money by a member to a limited liability company (LLC) classified as a partnership may be in the form of a capital contribution or a loan. This distinction has significant tax ...

Advisers focused on private clients commonly overlook planning for the income and estate taxes on income in respect of a decedent (IRD). This item discusses issues created by IRD and presents ...

Whether a taxpayer is subject to an accuracy-related penalty due to an understatement of tax is the most-litigated tax issue in recent years. Although the IRS wins a large majority of cases on this ...

Individuals are subject to two income tax systems: the regular income tax and the alternative minimum tax (AMT). Taxpayers must compute their tax under each system and pay the greater of the two ...

The federal income taxation of gains (and losses) from the disposition of investments in collectible assets (collectibles) is relatively unfamiliar to many practitioners for several reasons. First, ...

Annually, millions of Americans are granted stock options by their employer. The majority of recipients are high-net-worth individuals (or soon will be). The positive impact of this wealth-creation ...

In a world that is now a “global village,” even small firms must master cross-border tax issues to serve their clients well. There are two basic types of cross-border transactions. Outbound ...

Only infrequently will it be beneficial for a C corporation to convert into a limited liability company (LLC). Although a conversion allows the C corporation shareholders to continue to have limited ...